There has already been significant attention devoted to whether EPA’s “train wreck” of rules affecting coal-fired power plants would affect electric system reliability. The Congressional Research Service analysis looked at the coming rules more broadly, but did touch on reliability, noting that most of the coal plants likely to be retired as a result of EPA regulations are small and inefficient, and already run infrequently. As we noted last June, the Bipartisan Research Center did focus on reliability, concluding “that scenarios in which electric system reliability is broadly affected are unlikely to occur.”
However, this work has not been enough to satisfy FERC Commissioner Philip Moeller, who recently issued a “Request for Evidence” concerning the impact of EPA’s coming rules. The request is both deep and wide-ranging. It includes 22 separate questions, not including sub-parts. The questions range from the broad -- “What evidence supports the assertion of a reliability problem?” -- to the very specific -- "Will the loss of the system inertia that is supplied by coal plants impact the power grid in unforeseen ways? Does the topic of inertia require further study?”
In today’s polarized political climate, I’m not sure that there can be an answer to these questions that would satisfy everyone. At least inside the Beltway, decision-makers increasingly seem to know what they know, evidence be damned. Nonetheless, it can only help to have a more comprehensive analysis of the reliability issue by the government agency that has responsibility for ensuring electric system reliability. A careful assessment by FERC seems even more necessary in light of Wednesday's story in the Daily Environment Report to the effect that EPA's draft MACT rule contained an acknowledgement of reliability concerns when it was sent to the White House for review in February, but that the reliability discussion was edited out before EPA signed and issued the proposed rule in March.
For my part, assuming that the reliability issue can be addressed, I’d rather have the train wreck than Chinese water torture. Precisely because small coal plants might shut as a result of the cumulative weight of the EPA regulations, isn’t it better for everyone that the owners of those plants know about all of the regulations at the same time, rather than have them promulgated seriatim over a number of years? Wouldn’t the owners feel foolish -- and justifiably annoyed -- having spent a bunch of money complying with the first rule to be promulgated, only to decide that the second, or third, or fourth is the straw that breaks the camel’s back? As a matter of both public and private sector planning, it has to be better for EPA to be promulgating these rules in at least the same general time frame.